White v. Commissioner
United States Tax Court
The petitioner was not a bona fide resident of a foreign country or countries for a period of at least 2 years prior to the date in 1946 on which he changed his residence to the United States, under section 116 (a) (2), Internal Revenue Code, where he abandoned his foreign residence before the end of the 2-year period, even though he may have acquired no other residence until after that period.
1Opinion of the Court
OPINION.
BaaR, Judge:
To support his contention that he was a bona fide resident of a foreign country or countries for a period of at least 2 years before the date on which he reestablished his residence in the United States the petitioner puts forth two arguments. First, he argues that he was a resident of foreign countries continuously from 1937 to 1946, and that his presence in the United States during the period October 12,1941, to August 2,1944, for the purpose of securing medical treatment, did not constitute a break in his foreign residence. Our finding is to the contrary. In the…
2Cases cited9 opinions
- Johnson v. CommissionerUnited States Tax Court · 1946
- Swenson v. ThomasCourt of Appeals for the Fifth Circuit · 1947
- Commissioner of Internal Revenue v. NubarCourt of Appeals for the Fourth Circuit · 1950
- Seeley v. Commissioner of Internal Revenue. Seeley v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1951
- Seeley v. CommissionerUnited States Tax Court · 1950
4 more not listed; retrieve them via the Exa API.
3Cited by17 opinions
- Nelson v. CommissionerUnited States Tax Court · 1958
- Sochurek v. CommissionerUnited States Tax Court · 1961
- Meade A. Carpenter, Jr. v. United StatesCourt of Appeals for the Fifth Circuit · 1974
- Jellinek v. CommissionerUnited States Tax Court · 1961
- Matthew v. CommissionerUnited States Tax Court · 1962
12 more not listed; retrieve them via the Exa API.